Last week the New York Department of Financial Services (the “Department”) issued letters to all its licensed financial institutions. Based on these letters (available here and here), all Department licensees must assess and plan for the financial risk of COVID-19 and, separately, develop operational plans for managing their response to the virus. The Department requires […]
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California Attorney General Issues Second Round of Modifications to CCPA Regulations
At approximately 6:00 p.m. today, March 11, 2020, California Attorney General Xavier Becerra announced a second round of modifications to the draft regulations his office is preparing for the California Consumer Privacy Act (the “Draft CCPA Regulations”). These modifications follow two previous rounds of drafting: (a) the initial publication of the Draft CCPA Regulations, in […]
High Profile Settlements, Strengthened Data Security Orders, and COPPA: The FTC’s 2019 Privacy and Data Security Update
Each year the Federal Trade Commission (the “FTC” or “Commission”) publishes a report on its activities with respect to consumer privacy and data security during the prior year. On February 25, 2020, the Commission released its 2019 Privacy and Data Security Update. The update contains a summary of the FTC’s enforcement, advocacy, and rulemaking actions […]
California Passes Several Amendments to the California Consumer Privacy Act
The California legislature passed several amendments to the California Consumer Privacy Act of 2018 (Cal. Civ. Code §§ 1798.100 to 1798.190) (the “CCPA”) on September 13, 2019. (See our previous blog posts here: Which CCPA Amendments Made the Cut? and Potential Changes to the CCPA; California Senate Considers Amendments). These amendments will soon head to […]
FashionID: Another Significant ECJ Case with Potential Impacts Across the Adtech Ecosystem
On July 29, 2019, the European Court of Justice (“ECJ”) issued its decision in the case of FashionID GmbH & Co. KG v. Verbraucherzentrale NRW. The ECJ found that websites that integrate Facebook plugins are jointly responsible for the data collected by those plugins and sent to Facebook. Despite the somewhat innocuous-sounding holding, this decision […]